Dear Anon,

We got your letter regarding the discharge you have observed at the Memphis Zoo.  Dana did a file review in Nashville and found out that they do not have a National Discharge Elimination System permit. You were right!  In accordance with the Industrial Waste Survey, all of the zoo’s solid waste is taken off-site for disposal. They do have a permit for construction stormwater and we were curious to see that one of the  activities they described was “drainage structures”.  Drainage to where?

We are planning to look into this further. The next time we’re in Memphis we will ask to look at the construction permit to figure out what drainage structures they have and where they go.  If you have photos, you need to send them to us.  Digital photos are fine.

Thanks so much for thinking of us. If you want to contact me personally feel free to do so at 865.522.7007 x100.  We will keep all your information confidential.  Also, I’d happily join you for a visit to the zoo next time I’m in Memphis!

RvH

Last year EPA proposed some changes to the construction stormwater rules, referred to as effluent guidelines.  Overall, TCWN was supportive of more stringent requirements and assurances to protect our water quality.  The most discussed draft language was a numeric turbidity limit of 13 NTU.  I won’t bore you with too much explanation of what NTU means, but put simply it measures the clarity of water.  And 13 NTU is pretty clear water.  However, in the final rules issued last month, EPA upped the numeric limit to 280 NTU… quite a change.  As you can guess, 280 NTU isn’t nearly as clear as 13 NTU. 

Another big change was the application of these requirements to 20 acres and eventually 10 acres rather than larger sites, which was initially proposed.  This is good news.  There will most likely be challenges to these rules in the near future – perhaps from both sides.  For now, feel free to check out these new rules here.

On this blog we’ve talked about the rumors of greater enforcement actions (see October 15 and August 5 posts). Now the Obama Administration has put their money where there mouth is and followed up.

What does this mean for Tennesseans? Well, we’re not being left out.  EPA issued a demand letter to the Knoxville Utility Board for illicit discharges (illegal dumping) of sewage from 2005-2008.  These dates are for the years immediately following our lawsuit.

Then yesterday we found out about an enforcement action EPA took against a developer for guess what?  Stormwater runoff to the tune of $350,000!  That is freakin’ huge!

Finally, we’re getting some relief!

As most of you know we here at TCWN work closely with other states along the Mississippi River to address the nutrient loading problems resulting in the Gulf of Mexico Dead Zone.  While we may have the second largest dead zone sitting off our coast, it is most definitely a global problem.  According to this incredibly interesting recent article by Fred Pearce, there are over 400 dead zones across the globe and much of their existence and size is a result of our over usage of fertilizer.  This is a fascinating read.    

Check out the latest NY Times Toxic Waters article.  The fourth story in the series discusses the connection between air pollution and water pollution.  Specifically the article addresses how tightening air pollution restrictions have increased power plants’ contribution to water pollution.  What once went up, now comes down - into our waters.  Great read!